This is premium content. Please become a Premium member. If you are already a member, login here to access the full content.
Re Foster Wheeler France SA – Date of filing of the return is the relevant date to consider the applicability of the proviso to section 245R(2) of the Act
Case Law Details
- Case Name
- In Re Foster Wheeler France SA (AAR Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- Advance Rulings
Upgrade to Basic or Premium to download.
Already Upgraded? Log in.
In Re Foster Wheeler France SA (AAR)- Just like our considering the date of hearing of the application under section 245R of the Act would make for uncertainty, the fixing of the date of notice under section 143(2) / 142(1) of the Act by the income-tax authority as the starting point, would result in vagaries and to the use of different yardsticks to different applicants, it would depend on the diligence or non-diligence of the Assessing Officer, whether he had issued the notice before or after the application before this Authority has been filed and the nature of the notice.
A jurisdictio...
